AB Kauno alus (hereinafter referred to as the Company) respects the right to privacy and protection of personal data of its customers, employees, partners, visitors of its website (www.kaunoalus.lt) and other persons, and the Company undertakes to ensure the implementation of these rights in the course of its business. With this aim, the Company provides the following information in this Privacy Policy on how it, as a data manager, processes the personal data of natural persons.
Please read and get acquainted with the Privacy Policy of AB Kauno alus carefully, as this document contains all the information related to how, for what purpose and what personal data of natural persons is processed by the Company, as well as the rules it follows when processing them.
I. GENERAL PROVISIONS
1.1. The Privacy Policy has been drawn up in accordance with the General Data Protection Regulation 2016/679 (GDPR) in force in the European Union, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts regulating the protection of personal data.
1.2. The Data Manager is AB Kauno alus, legal entity code: 133698115, registered office address: Savanorių pr. 7, LT-44255 Kaunas, Lithuania.
II. TERMS USED
2.1. Personal data means any information or items of information from which an individual can be identified. Such data shall include a natural person’s name, surname, personal identification number, residential address, telephone number, e-mail address, IP address and other data relating to a natural person.
2.2. Processing of personal data means any act or combination of acts which involve the collection, recording, sorting, organisation, storage, alteration, use, disclosure, erasure or other processing of personal data, whether or not by automated means
2.3. The Data Manager is AB Kauno alus, legal entity code: 133698115, registered office address: Savanorių pr. 7, LT-44255 Kaunas, Lithuania.
2.4. Data Subject means a natural person whose personal data is processed by the Company. Such persons are considered to be the Company’s customers, employees, partners, visitors to the website (www.kaunoalus.lt), service providers or their representatives (if the service provider is not a natural person) and other natural persons who provide their personal data to the Company
2.5. Consent of the Data Subject means any freely given, specific and unambiguous indication of the data subject’s wishes, by means of a statement or an unambiguous action, by which he or she consents to the processing of personal data concerning him or her
2.6. Other terms used in the Privacy Policy but not specified in this paragraph shall be understood and interpreted as defined in the GDPR, the laws of the Republic of Lithuania and other legal acts governing the protection of personal data.
III. PROCESSING OF PERSONAL DATA. CASES OF DATA COLLECTION, PURPOSES OF PROCESSING AND DURATION OF STORAGE OF PERSONAL DATA
3.1. The Company’s processing of personal data:
3.1.1. strictly comply with the laws and other legal acts of the Republic of Lithuania and the GDPR governing the protection of personal data;
3.1.2. process personal data only in a lawful, fair and transparent manner in relation to the data subject;
3.1.3. ensures that personal data are collected for clearly defined and legitimate purposes and are not further processed in a manner incompatible with the purposes for which they were collected;
3.1.4. ensure that personal data are collected only as necessary to achieve the purposes for which they are processed;
3.1.5. ensure that personal data are accurate and updated when necessary. The Company shall take all reasonable steps to ensure that personal data which are not accurate in relation to the purposes for which they are processed are deleted or corrected without delay;
3.1.6. keep them only for as long as is necessary to permit identification of data subjects for the purposes for which the personal data are processed;
3.1.7. process personal data only in such a way and in such a manner as to ensure, through appropriate technical or organisational measures, the security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
3.2. The Company processes personal data based on at least one of the following grounds:
3.2.1. the data subject has given (expressed) consent to the processing of personal data for one or more purposes;
3.2.2. the processing of personal data is necessary for the implementation of a contract to which the data subject is a party or for the purpose of taking action at the request of the data subject prior to the conclusion of the contract;
3.2.3. the processing of personal data is necessary for the Company to comply with its legal obligations under the laws of the Republic of Lithuania and the European Union;
3.2.4. the processing of personal data is necessary for the purposes of the legitimate interests of the Company.
3.3. The Company shall carry out the processing of personal data in the following cases, for the following extent:
3.3.1. 2.3.1. by visiting the Company’s website (www.kaunoalus.lt), by filling in the enquiry form on the website, or by otherwise contacting the Company.
In cases when the personal data subject visits the Company’s website (www.kaunoalus.lt), the Company processes the following personal data: IP address, age category, see the provisions of Part IV of the Privacy Policy and the Company’s Cookie Policy.
In cases when the data subject fills in a request form on the Company’s website, the Company processes the following personal data of the natural person: name, e-mail address and other personal data specified in the request (if provided by the data subject). The personal data referred to in this paragraph is processed by the Company in order to respond to the website visitors’ queries related to the services provided by the Company. In this case, the lawful basis for the processing of the personal data is the data subject’s own consent to the processing of the personal data and, where applicable, the Company’s intention to take action at the request of the data subject prior to the conclusion of a contract. The retention period for the personal data referred to in this paragraph shall be 1 (one) year from the data subject’s last contact with the Company.
In cases when the Company is contacted by telephone or e-mail, depending on the nature of the contact, the Company may process any data voluntarily provided by the data subject, but generally this will include: the natural person’s name, surname, telephone number, e-mail address, workplace and job title (if the Company is contacted by a representative of a legal entity). In this case, the purpose of the processing of the personal data depends on the nature of the contact and the lawful basis for the processing of the personal data is the data subject’s own consent to the processing of the personal data and, where applicable, the Company’s intention to take action at the request of the data subject prior to the conclusion of the contract. The retention period for the personal data referred to in this paragraph shall be 1 (one) year from the data subject’s last contact with the Company.
3.3.2. when purchasing goods and/or services from the Company.
The following personal data of customers are processed when purchasing goods and/or services from the Company: name, surname, personal identification number (date of birth), residential address, telephone number, e-mail address, bank account number, signature and other data necessary for the proper provision of services or goods and for the payment, if the customer is a natural person. In case the customer is a legal person, the Company shall collect the following personal data: name, surname, job title, position, signature, telephone number and e-mail address of the customer’s representative. The processing of personal data referred to in this paragraph is based on the contract concluded between the Company and the client, and therefore the Company processes the personal data referred to in this paragraph in order for the Company to properly fulfil its obligations under the contract and the processing of the personal data is necessary for the performance of the contract. In this case, the retention period of the personal data is 5 years from the date of termination of such contract.
Irrespective of whether or not the Company’s customers purchase goods or services on the basis of a contract concluded between the parties, the Company collects the following personal data for the purpose of the performance of its financial accounting: name, surname, payment data. The data referred to in this paragraph are collected and processed for the purpose of fulfilling the Company’s obligations arising from the laws of the Republic of Lithuania and other legal acts. Such data shall be stored for 10 years in accordance with the procedure established by law.
3.3.3. when drawing up into and implementing other contracts not related to the provision of goods or services purchased from the Company.
In cases when the Company concludes other contracts (e.g. with raw material suppliers, couriers, etc.), not related to goods or services purchased from the Company, the Company processes the following personal data: name, surname, personal identification number (date of birth), residential address, telephone number, e-mail address, bank account number, signature and other data necessary for the proper provision of services or goods and payment, if the other party to the contract is a natural person. In case the other party to the contract is a legal person, the Company shall collect the following personal data: name, surname, job title, position, signature, telephone number and e-mail address of the customer’s representative. The processing of personal data referred to in this paragraph is based on the contract concluded between the Company and the client, and therefore the Company processes the personal data referred to in this paragraph in order for the Company to properly fulfil its obligations under the contract and the processing of the personal data is necessary for the implementation of the contract. In this case, the retention period of the personal data is 5 years from the date of termination of such contract.
3.3.4. when visiting the Company’s physical stores or factory premises.
The Company shall carry out video surveillance in its physical stores and factory premises to ensure the complete security of its employees, customers, visitors and its property. Personal data collected during video surveillance is processed on the basis of the legitimate interests of the Company. The data collected during video surveillance shall be stored for a maximum period of 60 to 90 calendar days, after which it shall be automatically deleted.
3.3.5. by conducting a search for candidates to fill vacancies in the Company.
In cases when the Company publishes information about the search for a new employee, the Company shall process the personal data of all candidates who have applied to the Company, which they provide in their CVs submitted to the Company. Such personal data usually includes: name, surname, telephone number, e-mail address, place of residence, information on education, work experience and other knowledge. The Company processes this data in order to select the candidate it considers most suitable for the vacancy and in accordance with the consent expressed or given by the candidates themselves to the Company’s processing of personal data. The personal data referred to in this paragraph shall be processed and stored until the end of the Company’s search for candidates, after which they shall be destroyed immediately.
3.4. The Company reserves the right to carry out the processing of personal data in other cases not specified in this paragraph, however, in such case the Company shall inform the data subject about the processing of personal data in relation to him/her, indicating the purpose and grounds for the collection of the personal data, as well as the scope of the data collected.
IV. COOKIES
4.1. The Company’s website (www.kaunoalus.lt) uses cookies, which are small text-based pieces of information placed on the computers or other devices of users who visit the Company’s website. Depending on the browser, this information may be stored in small individual files or in a common file of cookies stored by different websites.
4.2. Cookies help to identify visitors to the Company’s website on their next visit, to save a person’s browsing history, preferences, etc. Cookies are important since they speed up searches on the Company’s website, create user-friendly website environment, and make the website more efficient and reliable.
4.3. With the help of cookies, the Company collects the following data: the IP address, the type of web browser used, the number of visits to the Website, the pages viewed on the Website, the time spent on the Website, the age category and, if the visitor of the Company’s website is accessing the Website from a third country website, the URL link of the page.
4.4. By visiting the Company’s website, the data subject may object to or consent to the placing of cookies on his or her computer or other device. The data subject may withdraw his or her consent at any time by changing the settings of his or her web browser and deleting the cookies stored. For more information about the Company’s cookies, please refer to the Cookie Policy on the Company’s website (www.kaunoalus.lt).
V. RIGHTS AND OBLIGATIONS OF THE DATA SUBJECT
5.1. The data subject has the right to:
5.1.1. withdraw his or her consent at any time, if the processing of personal data was carried out on the basis of the data subject’s consent;
5.1.2. to obtain information on whether the Data Manager processes personal data relating to the data subject. If such data are processed, the data subject shall have the right to access them;
5.1.3. to request the Data Manager to correct or delete the personal data or to restrict or object to the processing of personal data relating to the data subject;
5.1.4. to request the transfer of the personal data held by the Data Manager to another Data Manager, and the Data Manager shall not prevent this;
5.1.5. the right to file a complaint with a supervisory authority.
5.2. In order to exercise the rights specified in the Privacy Policy, the personal data subject shall submit a written request to the Data Manager, which must be signed by the data subject or his/her authorized person and submitted by e-mail: info@kaunoalus.lt or physically delivered to the Data Manager’s address: 7 Savanorių pr. 7, 444255 Kaunas, Lithuania.
5.3. The Data Manager shall examine the Data Subject’s request no later than within one month from the date of receipt of the request and shall provide the Data Subject with information on the actions taken following the Data Subject’s request. The period referred to in this paragraph may be extended by a further two months, if necessary, taking into account the complexity of the request and the number of requests. The Data Manager shall inform the data subject of such extension within one month of receipt of the request, together with the reasons for the delay.
5.4. If the data subject submits a request by electronic means, the information shall also be provided to the data subject by electronic means where possible, unless the data subject requests otherwise.
5.5. The Data Manager shall provide a copy of the personal data processed. The Data Manager may charge a reasonable fee for any other copies (e.g. repeated copies) requested by the data subject, determined in accordance with its administrative costs.
5.6. The Data Subject shall also have the right to file a complaint with State Data Protection Inspectorate for the Data Manager’s acts or failure to act. The form of the complaint, the method of submission and the complaints procedure can be found on the website of the State Data Protection Inspectorate (https://vdai.lrv.lt/lt/).
VI. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
6.1. When processing personal data of natural persons, the Company shall ensure and guarantee the confidentiality and non-accessibility of personal data. The Company shall not disclose the personal data of natural persons to third parties, except in the following cases:
6.1.1. such transfer is related to the protection of the Company’s rights and legitimate interests (e.g. debt collection, taking legal action, bailiff, public prosecutor’s office, and other institutions);
6.1.2. such transfer is necessary for the pursuit of the data subject’s own interests (e.g.: transfer of the data subject’s general personal data to courier services, etc.);
6.1.3. the transfer is related to the proper performance of the Company’s business (e.g.: the transfer of personal data to the Company’s accountants or to a company that provides accounting services to the Company);
VII. FINAL PROVISIONS
7.1. Bendrovė pasilieka teisę vienašališkai atnaujinti, papildyti ir (ar) pakeisti atitinkamas šios Privatumo politikos nuostatas. Dėl šios priežasties, būtina reguliariai su šia Privatumo politika susipažinti. The Company reserves the right to unilaterally update, supplement and/or change the relevant provisions of this Privacy Policy. For this reason, it is necessary to consult this Privacy Policy on a regular basis.
7.2. In case of any further questions regarding the application of the provisions contained in this Privacy Policy, please contact the Company by e-mail: info@kaunoalus.lt.
